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COUNTY INVESTMENT POLICY
BOARD OF COUNTY COMMISSIONERS PALM BEACH COUNTY, FLORIDA
March 14, 2017
RESOLUTION NO. R-2017-0359
SHARON R. BOCK, CLERK & COMPTROLLER
BOARD OF COUNTY COMMISSIONERS
PALM BEACH COUNTY, FL
INVESTMENT POLICY STATEMENT
TABLE OF CONTENTS
PREFACE
I. SCOPE...................................................................................................................... 2
II. INVESTMENT POLICY COMMITTEE................................................................ 2
III. INVESTMENT OBJECTIVES
A. Safety...................................................................................................... 3 B. Liquidity................................................................................................. 5 C. Market Rate of Return............................................................................ 5
IV. DELEGATION OF AUTHORITY.......................................................................... 6 V. ETHICS AND CONFLICTS OF INTEREST.......................................................... 7 VI. AUTHORIZED INSTRUMENTS AND RISK DIVERSIFICATION METHODS
A. Eligible Securities............................................................................................... 8 B. Investment Limitations; Risk Diversification...................................................12 C. Criteria for Selection of Qualified Issuers of Eligible .....................................14 D. Safekeeping – Third Party Custodial Agreements...……………………….....19
VII. PROGRAM EVALUATION AND CONTROL
A. Internal Controls.……………………………………………………….……21 B. Program Monitoring…………………………………………………….…...23
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PREFACE
As custodian of the funds of the Palm Beach County Board of County Commissioners,
it is the duty of the Clerk & Comptroller (Clerk) to deposit revenue and issue payments
to bona fide creditors of the Board.
The purpose of the Investment Policy statement as required by Section 218.415,
Florida Statutes and Palm Beach County Investment Ordinance No. 87-11, as
amended, is to address such issues as liquidity, risk diversification, safety of principal,
market rate of return, maturity and investment quality, as well as qualifications of
investment dealers and issuers, thereby suggesting guidelines for use in the investment
of County funds.
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PALM BEACH COUNTY
INVESTMENT POLICY STATEMENT
I. SCOPE
This Investment Policy applies to all financial assets owned or controlled by the
County, under the custodianship of the Clerk.
II. INVESTMENT POLICY COMMITTEE Under County Ordinance No. 87-11, as amended, the Palm Beach County Investment
Ordinance, the Board of County Commissioners created the Investment Policy
Committee. The Committee was established for the purpose of developing, in
cooperation with the Clerk, this Investment Policy for the formal approval of the
Board. The Clerk and the Committee shall also evaluate the effectiveness of the Policy
as a guide for County investment practices. The Committee shall meet a minimum of
three times a year. A copy of the minutes of each Investment Policy Committee
meeting will be sent to each member of the Board of County Commissioners.
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III. INVESTMENT OBJECTIVES
The County shall strive to achieve with each investment opportunity, the following
objectives, in order of priority:
A. SAFETY of financial assets
B. LIQUIDITY of funds adequate for timely satisfaction of financial obligations
C. MARKET RATE OF RETURN - maximum achievable investment income
given prudent safety and liquidity objectives
Investments shall be made with judgment and care, under circumstances then
prevailing, which persons of prudence, discretion and intelligence exercise in the
management of their own affairs, not for speculation, but for investment, considering
the probable safety of their capital as well as the probable income to be derived from
the investment.
A. SAFETY: Monies entrusted to the Clerk represent monies belonging to the
people of Palm Beach County. Therefore, the primary objective of this
Investment Policy is to provide for the prudent investment of these funds.
The Clerk will avoid assuming unreasonable investment risk, and the safety
and soundness of any investment vehicle shall be the first criterion for any
investment decision. The following methods shall be used to mitigate risk:
1. CREDIT RISK (risk of loss due to failure of issuer/ backer):
a) investments shall be limited to the safest types of securities, as
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provided herein1,
b) investment transactions shall be limited to trades with those pre-
qualified and approved financial institutions as further described
herein2,
c) securities shall be transferred "Delivery" (to third party safekeeping)
"vs. Payment" (to seller)3,
d) the investment portfolio should be diversified according to parameters
stated herein, so that the failure of any one issuer, backer or market
sector will not place an undue financial burden on the County, and
e) the County's investments shall be monitored according to guidelines
approved by the Investment Policy Committee and the Clerk. In the
event of a downgrade of an investment security owned by the County
below the parameters as set forth by this investment policy, the Clerk’s
office will notify the County Investment Policy Committee within 30
days, and further make a recommendation as to what action is
appropriate.
1See VI.A.:Eligible Securities.
2See VI.C.:Qualified Dealers/Issuers; Criteria For Selection Of.
3See VI.D and VII.A.1. for third party safekeeping and internal controls regarding transfer of securities. Transfer may be effected by delivery of securities in bearer definitive form (physical form) or in book-entry form.
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2. INTEREST RATE RISK (risk of loss due to devaluation of market value
of portfolio during generally increasing interest rates):
a) the County's portfolio shall be structured when practicable so that
securities mature to meet the County's scheduled cash requirements, as
provided by the Office of Financial Management and Budget, thereby
avoiding the need to sell securities on the open market prior to their
maturation, and,
b) in the absence of reliable cash flow forecasts as required above,
investment maturities should be scheduled in accordance with those
parameters prescribed herein.
B. LIQUIDITY: Cash needs of the County constrain the investments made by
the Clerk. Bona fide creditors must be paid on a timely basis, therefore
investments shall be of sufficient marketability to ensure even unexpected cash
needs can be met, without suffering significant loss. This Policy consideration
means only the highest quality investments as authorized herein, shall be
acquired by the Clerk.
C. MARKET RATE OF RETURN: The investment portfolio shall be designed
with the objective of attaining a market rate of return throughout budgetary
and economic cycles taking into account the investment risk constraints and
liquidity needs.
1. PERFORMANCE MEASUREMENTS
In order to evaluate the performance and suitability of the investment
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portfolio in terms of its risk (interest rate) exposure and market rate of
return, the Investment Policy Committee has selected the yield of the 2-
Year Constant Maturity Treasury (CMT) as an index for comparison. To
measure the appropriate income or yield for the County investment
portfolio, we will benchmark the aggregate portfolio yield against the
yield of the 24-month moving average of the index. In addition, we will
compare the effective duration of the County’s portfolio to the duration of
the index to capture the County’s interest rate risk tolerance.
IV. DELEGATION OF AUTHORITY
Authority to manage the Board of County Commissioners' investment program is
derived from the following: State Constitution, Florida Statutes, and local ordinance.
Management responsibility for the investment program is hereby delegated to the
Clerk, who shall establish written procedures for the operation of the investment
program consistent with this Investment Policy. Procedures should include reference
to: safekeeping, PSA repurchase agreements, wire transfer agreements, banking
service contracts and collateral/depository agreements. Such procedures shall include
explicit delegation of authority to persons responsible for investment transactions. No
person may engage in an investment transaction except as provided under the terms
of this Policy and the procedures established by the Clerk. The Clerk shall be
responsible for all transactions undertaken and shall establish a system of controls to
regulate the activities of subordinate officials.
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Investment vehicles will be purchased via the competitive bidding process as
appropriate to ensure the attainment of competitive prices and/or yields.
The Clerk’s official(s) responsible for making investment decisions must annually
complete eight hours of continuing education in subjects or courses of study related to
investment practices and products.
V. ETHICS AND CONFLICTS OF INTEREST
Officers and employees involved in the investment process shall refrain from personal
business activity that could conflict with proper execution of the Investment Policy,
or which could impair their ability to make impartial investment decisions. Employees
and investment officials shall disclose to the Board of County Commissioners any
material financial interest in financial institutions that conduct business within the
County, and they shall further disclose any personal financial/investment positions
that could be related to performance, particularly with regard to the time of purchases
and sales.
VI. AUTHORIZED INSTRUMENTS AND RISK DIVERSIFICATION METHODS
This section provides Investment Policy statements regarding:
A. in which instruments the Clerk may invest – “Eligible Securities”
B. suggested portfolio composition limitations – “Investment Limitation; Risk
Diversification”
C. with which financial intermediaries and issuers the Clerk may conduct investment
transactions, and – “Criteria for Section of Qualified Issuers of Eligible Securities”
D. safekeeping measures – “Safekeeping – Third Party Custodial Agreements”
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A. ELIGIBLE SECURITIES
The Clerk may purchase/sell the following investment securities as authorized
under Section 3 of County Ordinance No. 87-11, as amended, and Florida
Statute 218.415, Section (16), at prevailing market prices/rates subject to the
various limitations hereinafter provided below:
1. Any intergovernmental investment pool authorized pursuant to the
Florida Intergovernmental Cooperation Act, as provided for in Section
163.01 of the Florida Statutes. Investments authorized under this section
are limited to no more than 20% of the market value of the total portfolio
(at the time of purchase) with any entity.
2. Negotiable direct obligations of, or obligations the principal and interest
of which are unconditionally guaranteed by the United States Government
at the then prevailing market price for such securities, including U.S.
Treasuries, obligations guaranteed by the Government National Mortgage
Association, Small Business Administration pools and certain Agency for
International Development (AID) bonds. Investments in Small Business
Administration pools are limited to no more than 20% (at market value)
of the total portfolio at the time of purchase.
3. Obligations of the Government Sponsored Enterprises (GSE’s), including
Federal Farm Credit Banks, Federal Home Loan Bank or its district banks
and Federal Home Loan Mortgage Corporation, including mortgage-
backed securities guaranteed by the Federal Home Loan Mortgage
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Corporation.
4. Obligations of the Federal National Mortgage Association, including
Federal National Mortgage Association participation certificates and
mortgage pass-through certificates guaranteed by the Federal National
Mortgage Association (U.S. "Instrumentalities");
5. Non-negotiable interest bearing time certificates of deposits, savings
accounts, or money market accounts in banks maintaining certification as
a Qualified Public Depository pursuant to Florida Statute 280-Security for
Public Deposits.
6. Domestic banker’s acceptances eligible for purchase by the Federal
Reserve System issued by banks having a Moody's or Standard and Poor's
commercial paper rating of at least A-1 or P-1. Investments in bankers’
acceptances shall be limited to a maximum amount of 15% of the market
value of the total portfolio at the time of purchase.
7. Prime commercial paper. For the purpose of this section, "prime"
commercial paper shall be defined as that commercial paper which has
received a Standard and Poor's rating of at least A-1 or a Moody's rating
of at least Prime-1;
Investments in commercial paper shall be limited to a maximum amount
of 25% of the market value of the total portfolio at the time of purchase,
with no more than 3% of the market value of the total portfolio invested
with any single issuer.
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8. Interest-bearing obligations with a fixed maturity of any corporation
within the United States. Investment in all corporate securities (including
asset backed instruments) shall be limited to:
a) 20% of the market value (excluding commercial paper) of the total
investment portfolio at the time of purchase.
b) those securities rated "AA" or higher by Standard & Poor's and
Moody's ratings services. Securities rated on the lower tier of the AA
rating must have a stable outlook to be eligible for purchase.
c) no more than 2% (at market value) of the total portfolio in the
securities of any single issuer.
d) those investment securities that are not convertible. Companies doing
business with Iran and with the Sudan, will be disqualified as eligible
Issuers.
9. Investments in any securities authorized by sections VI.A.- 2.,3.,4. may
be under repurchase agreements.
10. Securities and Exchange Commission registered money market funds
with the highest credit quality rating from a nationally recognized rating
agency.
11. Bonds, notes, or instruments backed by the full faith and credit of the State
of Israel, if the State of Israel’s foreign debt at the time of purchase is rated
“A” or higher by Standard & Poor’s and Moody’s ratings services and any
bonds purchased must have a maturity of five years or less. No more than
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3% (at market value) of the total portfolio at the time of purchase may be
invested in these securities.
Notwithstanding the provisions of section VI.C. of this investment policy
governing authorized broker/dealers, the Development Corporation for
Israel may act as an authorized broker/dealer for securities backed by the
State of Israel.
Though the securities listed are widely considered to be the safest of all
investments from the standpoint of credit and liquidity risk, the securities
listed previously under Sections VI. A. 5, 6, 7, 8, 10 and 11, carry
potentially greater credit risk. Therefore, special risk-monitoring
procedures shall be undertaken by the Clerk to evaluate and reduce this
potential risk.
The Clerk shall have the option to restrict investment in selected
instruments to conform to then-present market conditions. The
Investment Policy Committee will be notified by the Clerk of any threat
to the integrity of the investment portfolio.
Securities Lending
Securities or investments purchased or held under the provisions of this Policy
may be loaned to securities dealers or financial institutions with a minimum
net capital of $25 million, provided the minimum net annual earnings estimate
is at least $500,000. The loan must be collateralized at all times by cash with
a value of at least 102% of the market value of the securities loaned. All
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reinvestment of the cash collateral must be in accordance with this County
Investment Policy.
B. INVESTMENT LIMITATIONS; RISK DIVERSIFICATION
Portfolios will be appropriately diversified to control the risk of loss resulting
from over concentration of assets in a specific maturity, a specific issuer, a
specific instrument, a class of instruments, an industry, a market sector, and an
institution through which these instruments are bought and sold.
Diversification parameters as established herein will be reviewed and revised
periodically as necessary by the Clerk and the Investment Policy Committee.
1. INSTRUMENT QUALITY RATINGS
The Clerk may invest in instruments as authorized herein with ratings
equivalent to those issued by Standard and Poor's or Moody's as suggested
herein. The Clerk and the Investment Policy Committee will review and
approve a comparable NRSRO to be used when Standard & Poor's and
Moody's ratings are not available.
A comparable rating service is one for which name recognition is
widespread in the banking, investment banking or investment
communities with a corporate existence of five (5) years or longer.
2. INVESTMENT TERM TO MATURITY - PORTFOLIO
DISTRIBUTION
Term to maturity shall be governed by the County's safety and liquidity
constraints. As previously stated, maturities will be timed to coincide as
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closely as possible with known cash needs. A dynamic cash flow model
will be utilized to continually monitor the projected cash receipts, matched
against pending monthly liabilities. Unless matched to a specific cash flow
requirement, the Clerk will invest only in securities with either a final
maturity or an average life of (10) years or less. The Clerk will manage
the effective duration of the aggregate portfolio by using the duration of
the 2-Year Constant Maturity Treasury (CMT) as a guideline.
3. TYPE INSTRUMENT - PORTFOLIO DISTRIBUTION
The Investment Policy Committee may periodically suggest additional
risk-diversification guidelines regarding investment limitations in a
particular type instrument (issuer), term to maturity for that instrument
and/or restrictions as to the proportion of such type instrument which may
be purchased for inclusion in the portfolio from an individual institution.
Such recommendations should be revised periodically as appropriate for
the achievement of overall policy objectives.
Collateralized Mortgage Obligations
Total investments in collateralized mortgage obligations (CMOs) shall
be limited to 20% of the market value of the total portfolio, calculated at
the time of purchase.
CMOs must be issued by the Government National Mortgage Association
(GNMA), the Federal Home Loan Mortgage Corporation (FHLMC), or
the Federal National Mortgage Association (FNMA). CMOs issued by
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either FHLMC or FNMA are further limited to a combined maximum of
10% of the market value of the total portfolio at the time of purchase.
Investments in interest–only (IO), principal-only (PO) and inverse floaters
are strictly prohibited. Additional CMO tranche types that are not
permitted include non-sticky jump (NSJ), sticky jump (SJ), type 2 and
type 3 planned amortization class -PAC (22) and PAC (33), type 2 and
type 3 targeted amortization class -TAC (22) and TAC (33), and support
bonds (SUP).
All issues must pass the FFIEC High Risk Security test on a quarterly
basis. Any CMO issues held in the portfolio that fail the test shall
continuously be evaluated for possible sale. The median expected
prepayment rate provided by Bloomberg shall be used in determining the
average life of all CMO issues.
The official(s) responsible for making investment decisions will have the
expertise to manage derivative products, or those investments whose
value depends on the performance of underlying securities or assets,
allowable by this investment policy.
C. CRITERIA FOR SELECTION OF QUALIFIED ISSUERS OF ELIGIBLE
SECURITIES
All securities purchased shall be only those securities of authorized issuers of
eligible securities as stated within this policy. Documented lists or source
documents of these authorized institutions, dealers and issuers of the various
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eligible securities will be developed and maintained by the Clerk.
Authorized Broker/Dealers
(For securities other than certificates of deposit)
The Clerk’s office will maintain a list of Clerk authorized broker/dealers and
registered representatives to provide investment services, to be selected at the
Clerk’s sole discretion. The Clerk shall develop written criteria for the selection
of authorized broker/dealers and registered representatives. Criteria will be based
on but not limited to creditworthiness and at least five years of servicing local
government accounts. The ability and willingness to provide superior service and
competitive pricing will be contributing factors. Selected firms and clearing firms
may include primary and non-primary/regional broker/dealers with $15,000,000
minimum capital and the firm must qualify under Securities and Exchange
Commission (SEC) Rule 15c3-1 (uniform net capital rule). Firms interested in
conducting business with Palm Beach County must first become authorized as
follows:
New Broker/Dealer Application
Broker/Dealers must supply the following documents during the application
process:
1) Two years audited financial statements;
2) Proof of Financial Industry Regulatory Authority (FINRA) certification and
proof of state registration;
3) The credit rating of each broker/dealer if published by a nationally recognized
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authority.
4)Completed broker/dealer questionnaire provided by the Clerk’s office;
5)Certification of having read, understood, and agreed to comply with the County’s
Investment Policy; and
6)At least three references from other public entities, agencies, and/or organizations
that have an ongoing business relationship with the broker/dealer.
7)Report of the broker/dealer’s as well as each representative’s Central Registration
Depository (CRD) number as documented with FINRA.
The Clerk’s annual analysis and evaluation of active authorized
broker/dealers shall include the following:
1)A review of the annual financial statements of each broker/dealer.
2)A review of the credit rating of each broker/dealer if published by a nationally
recognized authority.
3)A review of the responsiveness and service level of each broker/dealer bidding
and offering investments to the Clerk’s office.
4)A review of the applicable state, federal, and national registration of broker/dealer
if the registration has changed from the previous year to include an inquiry of
each representative’s Central Registration Depository (CRD) number as
documented with FINRA.
Before engaging in investment transactions with the Clerk, the supervising officer
from each authorized securities broker/dealer shall submit a certification document.
The document will certify that the officer has reviewed and accepted the Investment
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Policy and objectives of Palm Beach County and further agrees to disclose potential
conflicts or risks to County funds that might arise out of business transactions between
the firm and the Clerk’s office or Palm Beach County. All authorized broker/dealers
shall agree to undertake reasonable efforts to preclude imprudent transactions
involving County funds.
The supervising officer shall agree to exercise due diligence in monitoring the
activities of other officers and subordinate staff members engaged in dealings with the
Clerk’s office. Employees of any firm bidding/offering securities or investments to
the Clerk shall be required to familiarize themselves with the County’s investment
objectives, policies and constraints.
Authorized issuers of commercial paper and/or banker’s acceptances shall maintain a
short-term debt-rating by Standard and Poor's or Moody's of at least A-1 or P-1,
respectively. These ratings shall also apply to issuers of non-negotiable certificates of
deposit with terms to maturity of one year or less. If the original certificate of deposit
term to maturity exceeds one year, the issuer must maintain a long-term debt rating of
"A" or better, as determined by Standard and Poor's or Moody's. The long-term debt
rating shall also be used to qualify issuers of banker’s acceptances.
Should an issuer of certificates of deposit not have its debt rated by Standard and
Poor's or Moody's as required herein, it may still be an authorized issuer if it maintains
a quarterly average ranking of at least 50 as published by the State of Florida’s Chief
Financial Officer in conjunction with the Florida public deposits program.
In addition to the above-stated requirements, authorized issuers of certificates of
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deposit must maintain state-certification as a Qualified Public Depository.
Any issuer of securities which fails to maintain the qualifications of an authorized
issuer as required herein and which has obligations outstanding which are held by the
County shall be immediately suspended from the list of authorized issuers. The
Investment management team will notify the Investment Policy Committee at a
regularly scheduled meeting as to the actions taken or not taken as appropriate and in
the best interest of the County, in addition to discussion regarding the future purchase
or sale of any affected securities or terms for future reinstatement of the issuer to the
list.
Repurchase agreements shall be negotiated only with:
1) the "primary securities dealers" (as designated by the Federal Reserve
Bank), or
2) Commercial banks, insurance companies, investment banking firms,
including the holding companies of these institutions, whose rating on
their long-term debt is in the two highest rating categories by Moody's
Investor Service or Standard & Poor's Corporation.
The County will have negotiated a master Repurchase Agreement with any institution
with which it enters into a specific repurchase agreement. Such an agreement will
address at a minimum the following issues:
1) Source of policies allowing repurchase agreements such as state law, local
ordinance, written policies, and/or unwritten management practices.
2) The frequency and method of pricing the underlying securities.
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3) Independent third parties acting as custodians shall hold securities
underlying term repurchase agreements separate from its assets as well as
from the Seller's assets. "Term" is understood to be defined as a period
greater than overnight.
4) Each party's rights in repurchase agreements including:
a) specifications for the delivery and custody of the underlying securities;
b) the rights of the purchaser to liquidate the underlying securities in the
event of default by the seller;
c) the required margin of market value of the securities over the cost of
the Agreements;
d) specifications for valuation of the underlying securities, as necessary,
depending on the term of the repurchase agreement;
e) the purchaser's rights to additional securities or a return of cash if the
market value of the underlying securities falls below the required
amount;
f) rights and/or specifications regarding substitution of securities;
g) remedial action should violation of agreement provisions occur.
5) Securities authorized for purchase are: negotiable direct obligations of
the U.S. Government, Federal Agencies, and Federal Instrumentalities.
D. SAFEKEEPING - THIRD PARTY CUSTODIAL AGREEMENTS
All securities purchased by the Clerk under this section shall be properly
designated as an asset of the County and held in safekeeping by a third party
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custodial institution.
No withdrawal of such securities, in whole or in part, shall be made from
safekeeping except by the Clerk as authorized herein, or his/her respective
designees.
Eligibility requirements for the County's third-party custodial institutions will
include continued maintenance of the institution's:
1. Capital and surplus stock of at least $500,000,000,
2. Separate custody account at the Federal Reserve Bank specifically designated
by the FED as restricted for the safekeeping of the member-bank's customer-
owned securities only, and
3. Federal Reserve Bank clearing account.
The Clerk will execute on behalf of the County, third party custodial agreement(s)
with its bank(s) and depository institution(s). Such agreements may include
letters of authority from the Clerk, details as to responsibilities of each party,
method of notification of security purchases and sales and delivery versus
payment requirements. Agreement(s) may also address safekeeping and
transaction costs, as well as procedures in case of wire failure or other unforeseen
mishaps and describing the liability of each party.
The actual obligations or securities, whether in book-entry or physical form, on
which trust receipts or confirmations are issued may be held by a third party
custodial bank and/or institution or a designated corresponding bank or custodian
institution which has a correspondent relationship to the County's third party
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custodian or its designated correspondent institution, who is acting on behalf of
and under the same obligations as the County's third party custodian.
Every authorized security purchased by the Clerk on behalf of the governing
body of the County must be properly earmarked and:
a) If registered with the issuer or its agents, must be immediately placed for
safekeeping in a location that protects the governing body’s interest in the
security;
b) If in book entry form, must be held for the credit of the governing body by a
depository chartered by the Federal Government, the State of Florida, or any other
state or territory of the United States which has a branch or principal place of
business in this state as defined in Section 658.12, Florida Statutes, or by a
national association organized and existing under the laws of the United States
which is authorized to accept and execute trusts and which is doing business in
Florida, and must be kept by the depository in an account separate and apart from
the assets of the financial institution; or
c) If physically issued to the holder but not registered with the issuer or its agents,
must be immediately placed for safekeeping in a secured vault.
VII. PROGRAM EVALUATION AND CONTROL
A. INTERNAL CONTROLS
The Clerk will maintain a set of written internal controls designed to protect
the County's investment assets and ensure proper accounting and reporting of
the transactions related thereto. Such internal controls will include details of
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delivery vs. payment procedures and trust receipt documentation. Such
controls and procedures shall be reviewed by the independent auditors as part
of the annual financial audit.
1. TRUST RECEIPT AND CONFIRMATION
The Clerk on behalf of the County’s governing body may receive bank
trust receipts or statements in return for investment of surplus funds in
securities. Any trust receipts or statements received must enumerate the
various securities held, together with the specific number of each security
held.
2. SALE OF SECURITIES
When the invested funds are needed in whole or in part for the purposes
originally intended or for more optimal investments, the Clerk on behalf of
the County’s governing body may sell such investments at the then-
prevailing market price and place the proceeds into the proper account or
fund of the County.
From time to time the County receives securities/investments that fall
outside of this Investment Policy due to settlement of legal and other
administrative proceedings. Said investments are not to be considered as
violations of this Investment Policy. Any such investments shall be
disposed of in a timely manner appropriate for the size and types of
investments.
The sale and purchase of securities will take into consideration any
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rebalancing objectives of the current strategy as is routinely discussed at
Clerk Internal Investment Policy Committee meetings.
3. DELIVERY VERSUS PAYMENT
All securities purchased or sold will be transferred "delivery versus
payment" (D.V.P.) or "payment versus delivery" to insure that funds or
securities are not released until all criteria relating to the specific
transaction are met.
B. PROGRAM MONITORING
1. REPORTING REQUIREMENTS
The Clerk shall prepare periodic investment reports and make these reports
available to the Investment Policy Committee and the Board of County
Commissioners a minimum of four times a year. Reports shall include
securities in the portfolio by type, book value, coupon, and market value as of
the report date. Reports shall be available to the public.
2. PERFORMANCE MEASUREMENTS
The County's portfolio shall be designed to attain a market rate of return taking
into account risk constraints and cash flow requirements. Performance shall be
measured not less than quarterly with the use of periodic reports. These reports
shall include appropriate information necessary to evaluate the portfolio. The
measurement focus shall be the portfolio as a whole versus individual
investments.
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